United States of America v. State of California et al
Filing
167
[WITHDRAWN pursuant to 170 Notice] REPLY by United States of America to RESPONSE to 2 Motion for Preliminary Injunction. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X, # 25 Exhibit Y)(Reuveni, Erez) Modified on 6/8/2018 (Donati, J). Modified on 6/11/2018 (Donati, J).
EXHIBIT H
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UNTIED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
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:
THE UNITED STATES OF
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AMERICA,
:
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Plaintiff,
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vs.
: No. 18-264
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THE STATE OF CALIFORNIA;
:
EDMUND GERALD BROWN, JR.,
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Governor of California, in
:
his Official Capacity;AND
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XAVIER BECERRA, Attorney
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General of California, in
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his Official Capacity,,
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Defendants.
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:
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VIDEOTAPED DEPOSITION OF:
TODD A. HOFFMAN
DATE:
TIME:
LOCATION:
REPORTED BY:
Thursday, April 12, 2018
9:23 a.m.
Department of Justice
950 Pennsylvania Avenue, NW
Washington, D.C.
Denise M. Brunet, RPR
Reporter/Notary
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212-279-9424
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A P P E A R A N C E S
On behalf of the Plaintiff:
EREZ REUVENI, ESQUIRE
LAUREN BINGHAM, ESQUIRE
U.S. Department of Justice
Civil Division
450 5th Street, Northwest
Washington, D.C.
20530
(202) 307-4293
erez.reuveni@usdoj.gov
On behalf of the Defendants:
CHRISTINE CHUANG, ESQUIRE
State of California
Department of Justice
Bureau of Children's Justice
1515 Clay Street
Suite 2100
Oakland, California
94612
(510) 879-0094
christine.chuang.doj.ca.gov
LEE I. SHERMAN, ESQUIRE
CHEROKEE DM MELTON, ESQUIRE
SATOSHI YANAI, ESQUIRE
State of California
Department of Justice
300 S. Spring Street
Suite 1702
Los Angeles, California
90013
(213) 269-6404
lee.sherman@doj.ca.gov
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ALSO PRESENT:
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Julie A.G. Koller
Louisa Slocum
Liana G.T. Wolf
Dan Reidy, Videographer
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C O N T E N T S
EXAMINATION BY:
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PAGE:
Counsel for Defendants
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HOFFMAN DEPOSITION EXHIBITS:
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Exh 9
PAGE:
Defendants' Notice of Videotaped
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*
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Deposition of Todd Hoffman
Exh 10
Supplemental Declaration of Todd Hoffman 14
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HOFFMAN CONFIDENTIAL DEPOSITION EXHIBITS:
*
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Exh 11
Immigration Detainer - Notice of Action
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Exh 12
Immigration Detainer - Notice of Action
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Exh 13
Record of Deportable/Inadmissible Alien
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Exh 14
Record of Deportable/Inadmissible Alien
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Exh 15
INS Secondary Referrals
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Exh 16
INS Secondary Referrals
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Exh 17
INS Secondary Referrals
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(*Exhibits attached to the transcript.)
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there a detainer that was placed on the file?
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A
I'm sure there was, yes.
I don't know
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if I have that information or not, but we would
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serve a detainer in that type of case.
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know we issued a detainer for this case.
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7
Q
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A
But those are not in the documents that
You did not give me those documents.
I
don't think you gave me the detainer with this
case.
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I
you were just reviewing, correct?
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Yeah.
Q
I would just represent for the record
that I'm just giving you the documents --
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A
Yes.
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Q
-- that were given to us today.
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So when did you receive -- or who
received this anonymous tip?
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A
I'm not sure who received the anonymous
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tip.
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assume that it was the information -- we put the
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contact number on the detainer and an individual
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made that call based on having that information to
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let us know that this individual is going to be
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released in the coming hours.
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I mean, again, in my experience, I can only
Q
So did the anonymous caller make the
call the same day as the date of release?
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A
I do not know.
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Q
Was the anonymous tip made to the field
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office?
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A
I don't know who received the anonymous
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tip.
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enforcement unit.
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number.
It typically wouldn't be to our field
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office.
If they use the number on the detainer,
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it would be to the actionable office.
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I imagine it would be our admissibility
Q
That should be the contact
And did someone in CBP eventually pick
up the individual?
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Yes.
We waited in the parking lot.
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believe two officers had to wait in the parking
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lot for four to five hours or so until this
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I
individual was released.
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Q
And then once the individual went into
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CBP's custody, then this individual was returned
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to Mexico?
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A
Yes.
I'm sure we took him back to the
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port of entry and then completed the case file and
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then repatriated him back to Mexico.
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MR. SHERMAN:
I'm going to identify as
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Exhibit 14, also confidential, this document.
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this is Bates numbers 18 through 23.
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And
(Hoffman Confidential Deposition
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